Though designated a person most qualified in response to a deposition subpoena on a corporation, the corporate representative is an ordinary lay witness whose testimony is admissible at trial only if based on her personal knowledge. Here, a PMQ offered a declaration in support of defendant’s summary judgment motion full of statements about defendant’s practices decades before the witness was employed by defendant. While the witness might have testified from the contents of business records that satisfied the criteria for the business records exception to the hearsay rule, here the witness made no attempt to show that the documents attached to her declaration satisfied those criteria, and many of the documents showed on their face that they fell outside the scope of the business records exception. Accordingly, the trial court erred in admitting the witness’ declaration and in granting summary judgment based on it. The difficulties in proving or disproving the facts pertinent to a disease (mesothelioma) with a lengthy latency period do not allow non-statutory exceptions to the Evidence Code’s requirements.